Home / FBAR Requirements for Crypto Accounts Over $10,000: What You Need to Know in 2025

FBAR Requirements for Crypto Accounts Over $10,000: What You Need to Know in 2025

FBAR Requirements for Crypto Accounts Over $10,000: What You Need to Know in 2025

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Enter your foreign crypto accounts to determine if you need to file an FBAR. The $10,000 threshold is based on the highest balance across all foreign accounts on any single day during the year.

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If you hold cryptocurrency on a foreign exchange like Binance, KuCoin, or Bitfinex, and your total balance across all foreign accounts ever hit $10,000 in a single year, you might be breaking the law-even if you didn’t touch a bank account. The IRS and FinCEN aren’t just watching your crypto trades anymore. They’re watching your wallets, wherever they’re stored.

What Exactly Is an FBAR?

FBAR stands for Foreign Bank and Financial Account Report. It’s not a tax form. It’s a disclosure form. You file it with FinCEN, a branch of the U.S. Treasury, not the IRS. The rule is simple: if you’re a U.S. person (citizen, green card holder, or resident) and you had more than $10,000 total in foreign financial accounts at any point during the year, you must file FinCEN Form 114. That’s it. No deductions, no exceptions-just a hard threshold.

People think FBAR only applies to bank accounts. That’s outdated. The law has covered foreign financial accounts since the 1970s, and over time, that definition expanded to include securities, mutual funds, and even insurance policies with cash value. Now, cryptocurrency accounts are on the radar.

Crypto Accounts and the $10,000 Rule

Here’s where things get messy. As of 2025, pure cryptocurrency accounts are still not officially required to be reported on FBAR. That’s because of FinCEN Notice 2020-2, which says virtual currency accounts don’t count unless they also hold traditional money like USD, EUR, or GBP. So if your account on Binance.com only holds Bitcoin, Ethereum, and Solana, you’re not legally required to report it-yet.

But here’s the catch: if your account holds even $1 of Euros alongside your Bitcoin, it becomes a hybrid account. And hybrid accounts? They’re fully reportable. That means you have to list the exchange name, your account number, and the highest balance in USD during the year-even if the crypto value dropped back down before year-end.

Let’s say you had $8,000 in Bitcoin and $3,000 in EUR on KuCoin on June 15. Even though your crypto was worth less than $10,000 on January 1 and December 31, you crossed the $10,000 threshold that day. You’re required to file. Many people miss this because they only check their year-end balances.

Who Has to File?

You have to file if you have financial interest or signature authority over a foreign account. Financial interest means you own it-directly or through an entity you control. If you’re the sole owner of a crypto wallet on a foreign exchange, that’s financial interest. If you’re a partner in a U.S. LLC that holds crypto on Bitfinex, and you own more than 50% of the LLC, you still have to report it.

Signature authority is trickier. It means you can move the money without needing someone else’s approval. If you’re the only person who can log into the exchange account and send Bitcoin out, you have signature authority-even if you don’t own the coins. That’s rare in personal accounts, but common in business setups where multiple people have access.

What Counts as a Foreign Account?

A foreign account is any account held with a financial institution outside the United States. That includes exchanges based in the EU, Asia, or anywhere else. Binance.com (not Binance.US), Kraken (EU), KuCoin, Bybit, Gate.io-all foreign. Even if you’re sitting in New York, if the exchange is registered in the Cayman Islands or Singapore, it’s foreign.

U.S.-based exchanges like Coinbase or Kraken US? Not reportable. Even if you’re trading crypto, if the platform is legally registered and regulated in the U.S., it doesn’t trigger FBAR. The key is where the company is headquartered and regulated, not where you live.

A desk with crypto wallets spilling coins and Euros, a smoking calculator, and a giant ,000 alarm clock in cartoon style.

How Do You Calculate the ,000 Threshold?

You don’t add up your yearly totals. You find the highest value your foreign accounts reached on any single day in the year. Then you add up all your foreign accounts-crypto and fiat combined-on that day.

Example: On March 3, your Binance account had 0.5 BTC ($25,000) and 1,000 EUR ($1,050). Your KuCoin account had 2 ETH ($5,000). Total: $31,050. You hit the threshold. You must file FBAR, even if your balance dropped to $1,200 by December 31.

Valuing crypto is the hardest part. You need daily records in USD. You can’t guess. You can’t use average prices. You need to document the exchange rate and price at the exact time your balance peaked. Most people use crypto tax software like Koinly, CoinTracker, or TokenTax to track this automatically.

Should You Report Anyway? The Conservative Approach

Here’s the real question: even if you’re not legally required to report pure crypto accounts, should you?

Many tax pros say yes. Why? Because FinCEN has said they’re planning to change the rules. In Notice 2020-2, they wrote: "FinCEN intends to propose amendments to include virtual currency accounts as reportable accounts under FBAR." That’s not a rumor. It’s official. And when they do, they won’t give you a free pass for past years.

Imagine this: you didn’t report your Binance account in 2024. In 2026, FinCEN changes the rule and says crypto accounts are reportable starting January 1, 2025. Now they look back at 2024 and say, "You had $15,000 in crypto. Why didn’t you report it?" You can’t say, "But the rules didn’t say so back then." They’ll argue you should’ve known. And penalties for willful non-compliance can be up to 50% of your account balance per year-or $100,000, whichever is higher.

People who file anyway-even when not required-report fewer audits, fewer penalties, and less stress. It’s like wearing a seatbelt when the law doesn’t require it yet. You’re not breaking the law by reporting early. You’re protecting yourself.

What Happens If You Don’t File?

Non-willful failure to file? Up to $10,000 per violation. Willful? Up to $100,000 or 50% of your account balance, whichever is greater. And it’s per account, per year. If you had three foreign crypto accounts and didn’t file for three years? That’s $300,000 in potential penalties.

And it’s not just about money. The IRS shares data with FinCEN. If you filed Form 8938 (FATCA) and didn’t mention your foreign crypto accounts, they’ll notice. If you got a 1099 from Coinbase and didn’t report income from Binance, they’ll connect the dots. The IRS now has tools to track crypto transactions across hundreds of exchanges globally.

A man on a cliff labeled 2024 as a giant FBAR form crashes down toward him from a clock ticking to 2026 in cartoon style.

How to File

You file electronically through the BSA E-Filing System. No paper forms. You need:

  • Your personal info (name, SSN, address)
  • Details for each foreign account: exchange name, address, account number
  • The maximum value of each account in USD during the year
  • Your signature (electronic)

Most people use tax software that integrates with FinCEN’s system. If you’re filing on your own, you can do it at bsaefiling.fincen.treas.gov. But you can’t file if you’re not a registered BSA filer. Most individuals file directly. Tax preparers must register first.

Deadline is April 15, but you get an automatic extension to October 15. No request needed. Just file by then.

What Experts Are Saying

There’s a split in the crypto tax world. Firms like CoinLedger and some big accounting firms say: file now. Don’t wait. It’s cheaper than a penalty. Others, like Bitwave and crypto-focused law firms, say: follow the letter of the law. FinCEN’s notice says no, so no.

The truth? The law is in flux. If you have more than $10,000 in foreign crypto, you’re playing with fire. Even if you’re technically safe today, the rules are changing fast. The Infrastructure Investment and Jobs Act already forced crypto brokers to report transactions. The next step? Making FBAR mandatory for crypto.

What You Should Do Right Now

1. List all foreign crypto accounts you’ve ever had since 2020. Include Binance, KuCoin, Bybit, Gate.io, etc.

2. Check your highest balance on each account for each year. Use your exchange statements or tax software.

3. Add them up for each year. Did any year hit $10,000 or more? If yes, you need to file for that year.

4. File missing FBARs if you didn’t. Use the Delinquent FBAR Submission Procedures. You won’t get penalized if you file voluntarily before they contact you.

5. Start tracking daily if you still hold foreign crypto. Use software. Don’t rely on memory.

6. Separate your accounts. If you have fiat + crypto on one exchange, move the fiat to a U.S. bank. Keep crypto on foreign exchanges only if you’re comfortable with the risk.

There’s no shame in filing early. The people who get caught aren’t the ones who filed. They’re the ones who thought, "It’s probably not required."

What’s Coming Next?

By 2026, FinCEN will likely require FBAR reporting for all foreign crypto accounts. It’s not a question of if-it’s when. The Treasury has been signaling this for years. Crypto brokers are already reporting to the IRS. The next step is linking those reports to foreign account disclosures.

If you’re holding crypto overseas, you’re already in the crosshairs. The government isn’t waiting for you to catch up. They’re building the system to catch you before you even realize you’re in trouble.

16 comment

Abhishek Bansal

Abhishek Bansal

bro i just keep my crypto on binance and ignore this whole thing. if they want it they can come get it lol.

Scot Sorenson

Scot Sorenson

So let me get this straight. You're telling me that if I have $9,999 in BTC and $1 in EUR on KuCoin, I'm suddenly a criminal? That's not law, that's a trap. Who the hell keeps $1 in EUR just to trigger this?

Ike McMahon

Ike McMahon

Use Koinly. Seriously. It auto-tracks your highs and exports the FBAR-ready data. Saved me from panic mode last year.

Anselmo Buffet

Anselmo Buffet

i filed my 2023 fbars last week. took 20 minutes. no stress. just do it.

Taylor Fallon

Taylor Fallon

i think the real question isn't whether you're legally required to file-it's whether you want to live with the weight of knowing you might be one audit away from losing everything. the system isn't designed to be fair. it's designed to catch you when you're not looking.

PRECIOUS EGWABOR

PRECIOUS EGWABOR

if you're not filing, you're basically betting your life savings on the government being too lazy to update their spreadsheet. that's not a strategy. that's a funeral plan.

Caroline Fletcher

Caroline Fletcher

they're putting trackers in your crypto wallets next. mark my words. this is step one of the surveillance state. they want to know where every satoshi is at all times.

Heath OBrien

Heath OBrien

i had 12k in btc on binance in 2022 and didn't file. now i'm scared to even log in. what if they already have my ip? what if they're watching me right now??

Bridget Suhr

Bridget Suhr

i get why people are nervous. but i also think we're letting fear drive the conversation. the law is messy, sure-but filing early isn't a sign of weakness. it's just being smart. i filed mine even though i was technically in the gray zone. peace of mind is worth more than a few hours of paperwork.

Albert Chau

Albert Chau

You people are so naive. The IRS doesn't care if you 'think' you're safe. They don't care about your 'gray zones.' They have your data from every exchange, every wallet, every transaction. If you didn't file, you're already flagged. The only question is when they come knocking.

Toni Marucco

Toni Marucco

The philosophical underpinning of FBAR is not taxation-it is transparency. The state has a legitimate interest in knowing where its citizens' financial assets reside, especially when those assets exist in unregulated, pseudonymous systems. To resist this is not to assert liberty-it is to embrace opacity as a virtue. And opacity, in a world of algorithmic oversight, is not freedom. It is vulnerability.

Kathryn Flanagan

Kathryn Flanagan

so i just want to say, if you're new to this whole fbars and crypto thing, don't panic. i was terrified too. i had like five different accounts across binance, kucoin, and bybit and i didn't know what to do. but i found this free guide on reddit-actually, it was posted by someone named u/taxnerd42-and they walked me through how to export my history from each exchange and how to use cointracker to find the peak balances. it took me three weekends, but i filed all my missing years. and guess what? no one called me. no one came to my house. i just felt better. like, really better. like i wasn't carrying this secret anymore. you can do it too. just start with one exchange. one day at a time.

Nicholas Ethan

Nicholas Ethan

The premise of this post is flawed. FinCEN has never asserted jurisdiction over pure crypto accounts under FBAR. Citing Notice 2020-2 as a reason to file is not compliance-it is overcompliance born of fear. You are not protecting yourself by filing incorrectly. You are creating a paper trail that could be weaponized against you if the rules change. The law is clear. Until it changes, do not file. Do not volunteer. Do not panic. Do not enable regulatory creep.

Jessica Petry

Jessica Petry

It's fascinating how people will bend over backward to justify ignoring legal obligations, then act shocked when the consequences arrive. You wouldn't drive without a seatbelt because 'the law doesn't require it yet'-so why treat your life savings any differently? The fact that you're even debating this shows how deeply disconnected we've become from basic responsibility.

Hari Sarasan

Hari Sarasan

Institutional inertia in regulatory frameworks is a well-documented phenomenon. The convergence of AML/KYC regimes with decentralized finance necessitates a paradigm shift in financial disclosure architecture. Your current posture of non-compliance, predicated on semantic loopholes in FinCEN guidance, is not a strategic advantage-it is a temporal miscalculation with exponential liability exposure. I implore you: align your fiduciary conduct with the trajectory of regulatory evolution, not its current static form.

Joey Cacace

Joey Cacace

I filed my FBARs last year even though I wasn't sure I had to. I cried after I hit submit. Not because I was scared-but because I finally felt like I wasn't lying to myself anymore. đź’›

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